FINRA Rule 4522(b)(1) and Certain Capital Balance Funds
Q: If a member firm performs securities counts, verifications and comparisons as described in the January 6, 2026, Raymond James No Action Letter (the Letter),* would compliance with all circumstances set forth in the Letter satisfy the requirements of FINRA Rule 4522(b)(1) with respect to capital balance funds, as defined in that Letter?
* See Letter regarding Capital Balance Fund Reconciliations from Raymond A. Lombardo, Assistant Director, SEC Division of Trading & Markets, to Mark M. Attar of Stradley Ronon Stevens & Young, LLP and counsel to Raymond James & Associates, Inc. (January 6, 2026), https://www.sec.gov/files/tm/no-action/raymond-james-associates-inc-010626.pdf.
A: Yes. FINRA interprets Rule 4522 such that compliance with all circumstances set out in the Letter is deemed to comply with the requirements of FINRA Rule 4522(b)(1).